Professor Weaver is to be commended for her thorough and insightful analysis of offshore safety following the tragic loss of the MODU Deepwater Horizon and consequent oil spill in the Gulf of Mexico in 2010. (1) As one of the initial Federal On-Scene Coordinators for the oil spill response, I certainly value every study and recommendation that focuses on improving offshore safety.
The month long Macondo Gulf of Mexico spill response itself was full of high-risk offshore activities involving thousands of people from its beginning to end. I experienced personal accountability for offshore safety in the same way major oil company executives experience it. Every day you want to do something more, if possible, to prevent an accident.
Professor Weaver's two-part article focuses on offshore activities that are permitted by the U.S. Interior Department and regulated by the Bureau of Safety and Environmental Enforcement ("BSEE") and the U.S. Coast Guard ("USCG") according to the Outer Continental Shelf Lands Act ("OCSLA") as amended. (2) My opinion is that offshore safety recommendations ought to consider all oil and gas related offshore activities, including state-permitted well operations, Transportation Department regulated pipelines, and the many non-OCSLA regulated offshore activities such as helicopter and crew boat transportation, offshore construction, and spill response.
How should safety be improved offshore?
I considered improving safety as my primary goal as a career Coast Guard officer and as the Department of Interior appointed director of the newly created BSEE from 2011 to 2013. Professor Weaver's articles provide a very fair, detailed description of key portions of offshore regulatory history and the agenda during the period I was the BSEE director. I certainly agree with her general statement that offshore safety in the United States is a "work in progress." (3) I'm proud of that and hope it is always a work in progress. I believe highly effective organizations, both private and public, must be learning organizations willing to listen, change, and show measurable results.
There are indicators that BSEE's efforts, along with partner agencies and the industry itself, are achieving results. For example, the death toll from offshore industrial accidents in 2014 was significantly lower than in previous years, with only one casualty. (4) That's not a trend, just a data point. However, 2014 was a very busy year in the Gulf of Mexico...